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FIRE SERVICE AND GENERAL FIRE SAFETY TOPICS => Fire Safety => Topic started by: Davidrh on July 23, 2008, 05:00:33 PM
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Can anyone help
I have a fourty bedroom hotel that complied with all fire regulations and has been yearly inspected
Our local fire officer now require us to fit smoke seals on all our door including bedroom doors
I fully understand the need for safety but is this really necessary and is it a legal requirement.
Can the local fire office enforce this requirement
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See prosecutions section, regarding smoke in escape route of care home (sleeping risk).
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Under previous legislation the fire authority were unable to enforce improvements to premises once they had issued a fire certificate. Standards became frozen.
The new fire safety order swept that away and requires the responsible person to carry out a risk assessment and apply the principles of prevention in controlling hazards. One of these principles is that you should adapt to technical progress.
In the 1980s it was realised that the old fire tests for doors were unrealistic as they did not replicate what really happens when a room is involved in fire- the bouyancy of the hot smoke and gases , and thermal expansion cause an increase in air pressure within the room that pushes smoke and hot combustion products out around the door. It was then found that fire and smoke seals were necessary in order for doors to withstand the effects of fire for the designated period.
So there is good reason for doing it- there are seals available that can be fitted in minutes without any woodwork subject to gap sizes etc. See www.envirograf.co.uk for example. You could produce an action plan to carry out the improvements on a risk based phased basis- like doors to staircases first, then doors in dead end corridors, then doors in other rooms starting from the top downwards.
Legally you could perhaps have some grounds to challenge the requirement if your doors were in very good condition and well hung, as good as the day they were installed but because of the principles of prevention the odds would be stacked against you convincing the magistrate on appeal.
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Firstly, I agree with Kurnal as to the logic of the upgrade to fire doors but and it is a big but you can not be required to do it. It is a great recommendation and will do all those things that Kurnal has mentioned in the post. What you need to do is have a Fire Risk Assessment undertaken and follow the outcomes of that process with one of the outcomes being that you upgrade the fire doors. Fire door sets are tested to a standrad and the old BS 476 standrad did not have intumescent strips and smoke seals as part of it. The latest test version BS 476 part 22 does have so all new door sets are fitted with both strips and seals. Door sets to the old standard passed the test and will still provide protection although not to the latest standard.
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Ref my first question.
Is there specific information on hotel bedroom doors rather than exit door.
We have excellent self closing fire door on all our bedrooms and the question of smoke seals has never come up before during FB inspections.
Apart from the costs of doing this (which to be done properly measures in the Thousands) the disruption to the hotel would be significant.
Also I am concerned that the very act of installing shields will compromise exisiting fire doors
I am all for compliance and in no way wish to compromise fire safety at the hotel but is there not a principal of "reasonable & practical" .
I am also confused by a report from the fire safety reform think tank that states that
"There is no specific legal requirement to install smoke seals in existing fire doors that were not fitted with them when they were first installed in the building."
There surely has to be a common sense approach balancing safety with practicality
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So, slight change of circumstances, would heat detection within a hotel room still be acceptable?????? It was acceptable at the time.
My stance would be yes for strips and seals on all corridoor seperation, stairwell doors, rooms of higher risk and take a sensible approach on the bedroom doors.
My view only of course.
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David
Your right there are no legal requirements for your doors but it is good practice to upgrade them if possible and to give a bit more protection to escape routes. Either carry out a fire risk assessment or have a competent assessor do one for you, then you can go back to the Inspecting officer with possibly an alternate solution, there may be alternatives or your doors may be quite good. Get another opinion.
Check out the link in Kurnal's post with regard to Envirograf they do well over 100 products. Many of the smoke and intumescents seals can be fitted without any need to route doors or frames and can be fitted within minutes without disruption to guests or the busines, they are also available in different colours. And costs are reasonable, a client recenlty fiited them to his hotel doors for around £20 a door plus labour
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DavidRH, just for clarity, are you talking about doors between the rooms and the corridor?
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Hello and thank you all for your help
The doors I have the main concern with are the room doors. ie between the corridor and the rooms which are all self closing hotel bedroom fire doors and as I have said have never been an issue with the FSO before.
The other think that concerns me is that I have the immpression that the FSO is not to sure of his ground anyway.
When I quiried this requirement he said he would have to go away and ask a colleague and then came back with the blanket statement that he has been told that all doors marked in red on our fire plan must have smoke seals
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So have they served an enforcement notice requiring you to this or is it a goodwill recommendation?
Do you have smoke or heat detectors in bedrooms?
Have you carried out a risk assessment and if so have the fire authority commented as to whether it is suitable and sufficient?
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Hi Kurnal
No enforcement notice just as you put it a goodwill recommendation
We have heat detectors in the rooms and yes I know what you are going to say.. but hotels really really struggle with smoke detectors (false alarms)...believe me its not easy to convince customers not to smoke even though we are a non smoking hotel (all areas) again I site the need for a common sense approach balancing safety with practicality.
We have carried out a full risk assesment and the fire authority seem happy with it
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Hi Kurnal
No enforcement notice just as you put it a goodwill recommendation
We have heat detectors in the rooms and yes I know what you are going to say.. but hotels really really struggle with smoke detectors (false alarms)...believe me its not easy to convince customers not to smoke even though we are a non smoking hotel (all areas) again I site the need for a common sense approach balancing safety with practicality.
We have carried out a full risk assesment and the fire authority seem happy with it
If the fire authority have accepted your risk assessment and not been concerned enough to undertake any enforcement procedures other than for good will advice then is their letter of goodwill advice not simply ensuring that the moral burden of responsiblility is sitting on your shoulders?
They appear to be formally telling you that everything is ok but could be better, there is some residual risk and it may be practicable for you to make improvements but its down to your judgement as to what is reasonably practicable taking into account difficulty, cost, disruption etc and if the problems grossly outweigh the benefits then your duty of care is met.
Theres really no need for false alarms in a properly designed and maintained alarm system but theres many threads on that.
I would think a risk based action plan as I outlined earlier would go some way to proving due diligence.
In all honesty many of your peers are in a similar position, some just dont want to or unable to spend the money to address the hazards after many years secure under the Fire Certificate control, whilst others take a realistic view of the risk and put together an action plan for improvements based around other risk and refurbishment etc.
Its all down to your judgement and its your responsibility at the end of the day.
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I thinks one of the problems with this issue is that many people seem to think that the provision of a smoke seal will solve a problem of smoke leakage around a door. This is not the case.
One of the properties of a fire door is that it has to be capable of withstanding the passage of smoke at ambient temperatures. Some people seem to think that one of its properties is a smoke seal fitted. Bunging on a smoke seal does not necessarily provide smoke sealing. A good fitting fire door without a smoke seal can be just as effective.
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It goes back to understanding fire and its compontents parts and what protection is afforded by various methods including doors and strips and seals.
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If I can first pick up on post from nearlythere.
Can't think that I have come across a perfect sealing fire door without a smoke seal fitted.
In the run up the introduction of BS5588 Offices and Shops and subsequent introduction of BS476 31.1 in the early 80's it was recognised that the gap between the leaf and frame offered no significant smoke stopping qualities.
The revisions to the above specified a maximum leakage rate of 3 metres3/hour/metre at a pressure of 25Pa. A standard that could only be achieved by a flexible smoke seal.
On the matter of whether or not to fit smoke seals to hotel bedroom fire doors I consider it vital to fit seals to such doors. If any of my staff were carrying out an assessment on behalf of a hotel client I would expect a recommendation to fit smoke seals to selected fire doors including those to bedrooms.
As Kurnel rightly implied. From 01.10.2006 existing fire standards would have needed to be reviewed taking into account new/revised benchmark standards in conjunction with the new RRO guide for such premises.
Suprised the FA did not include the provision on an enforcement notice. I sense an inconsistency!!! Confused as to how a FA can issue a goodwill comment on smoke seals in such circumstances. under the current regime.
Davidrh, the only legal requirement is to undertake a 'suitable and sufficient' assessment of the risk. If you or your assessor feel that a case can be argued for not fitting smoke seals then go for it. In my opinion you will fail. Is it worth taking the chance?
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On the matter of whether or not to fit smoke seals to hotel bedroom fire doors I consider it vital to fit seals to such doors. If any of my staff were carrying out an assessment on behalf of a hotel client I would expect a recommendation to fit smoke seals to selected fire doors including those to bedrooms.
Steve,
Would you not consider it appropriate to assess the door for smoke sealing properties or the lack of it, fit smoke seals if considered necessary and re-assess that the fitting of the smoke seals will fulfil the function for which it is provided?
Or just fit smoke seals.
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Always liking a challenge, try this; As 5839 allows heat detection in hotel bedrooms it could be argued that the occupant of the room may kill himself by setting fire to his room. However he may not kill or endanger other occupants. Therefore the smoke from the fire should be permitted to gradually leak into the corridor, setting off the corridor smoke detection and warning other residents to evacuate before the bedroom door fails.
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Hi nearlthere
We do carry out a visual assessment of all fire doors.
What we come across is that you could ''count on one hand'' the number of good fitting doors. When we take into account the results of tests I am convinced that the fitting of cold smoke seals to hotel fire doors is vital. I feel that any other approach would be failing to provide my client with ''best'' advice.
My advice would be to set a programme of work perhaps over several years rather than months. This would reduce the immediate burden on the client (a matter close to the Governments heart when they considered the introduction of the RRO). Unfortunately some fire authorities don't appreciate the importance an effective programme against getting standards in place post 10.2006, standards that they had no powers to require under the FPAct 1971.
A possible future scenario.
Fire door fails to prevent the passage of smoke into a corridor resulting in fatalities due to smoke inhalation.
Client informs me that post incident he was told that fire tests carried out in the 80's recommended smoke seals. You can imagine the next question.
Dusty
Regarding your comment on smoke being allowed to enter the escape route before it hits a smoke detector is prehistoric.
I go back to the effective programme route of replacement smoke for heat in the bedrooms.
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Hi nearlthere
We do carry out a visual assessment of all fire doors.
What we come across is that you could ''count on one hand'' the number of good fitting doors. When we take into account the results of tests I am convinced that the fitting of cold smoke seals to hotel fire doors is vital. I feel that any other approach would be failing to provide my client with ''best'' advice.
My advice would be to set a programme of work perhaps over several years rather than months. This would reduce the immediate burden on the client (a matter close to the Governments heart when they considered the introduction of the RRO). Unfortunately some fire authorities don't appreciate the importance an effective programme against getting standards in place post 10.2006, standards that they had no powers to require under the FPAct 1971.
A possible future scenario.
Fire door fails to prevent the passage of smoke into a corridor resulting in fatalities due to smoke inhalation.
Client informs me that post incident he was told that fire tests carried out in the 80's recommended smoke seals. You can imagine the next question.
Dusty
Regarding your comment on smoke being allowed to enter the escape route before it hits a smoke detector is prehistoric.
I go back to the effective programme route of replacement smoke for heat in the bedrooms.
Steve. If the fitting of smoke seals is vital why have a several year programme? They can't be that vital.
How does the smoke detection in the corrider operate if the doors prevent the passage of smoke? Surely your risk assessment would recommend the provision smoke seals on doors to corridors which then means that smoke detection in the corridors is not necessary?
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nearlythere
What I am saying is not necessarily priority one but vital within the programme.
It may be me but I cannot understand your second point (its been a long day)
What I am advocating is smoke detection in bedrooms and corridors. Fire in bedroom would be picked up by detection before smoke has a chance to enter the corridor, hopefully giving building occupants in the area more time to evacuate.
Surely the prime function of smoke detection in corridors should not be as the first line of defence from a fire in a bedroom.
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Always liking a challenge, try this; As 5839 allows heat detection in hotel bedrooms it could be argued that the occupant of the room may kill himself by setting fire to his room. However he may not kill or endanger other occupants. Therefore the smoke from the fire should be permitted to gradually leak into the corridor, setting off the corridor smoke detection and warning other residents to evacuate before the bedroom door fails.
Somewhere in this forum HRH Colin Todd has posted an excellent summary of the rationale linking smoke detectors in rooms and fire door seals. Its well worth a read. And he refers to detailed test and modelling carried out by the BRE many years ago to study the effectiveness of smoke detectors in corridors, smoke seals on doors etc. The Rt Hon John S Webb has also posted details of this on this forum- well worth a search.
Theres just a couple of points I want to offer in response to Dustys posting. The BRE tests indicated that without seals on doors, most of the smoke that gets into the corridor actually comes from pyrolisis of the timber in the gap betwen the door leaf and frame rather than from the seat of the fire in the room itself, it is therefore cool and not bouyant enough to reach the detectors at ceiling level in some circumstances. Smoke detectors of the day in hotel rooms did give much earlier warning of fire but led to many false alarms which led to a reluctance by guests to respond to fire alarms creating further danger. Modern multi sensor alarms can deal with most of these but at about 6- 10 times the cost of a conventional detector. Heat detectors in rooms give ample warning to protect the means of escape and no false alarms.
The idea ( I think Fred posted this some time ago) of heat detectors in rooms linked to the main fire alarm system, coupled with a mains powered domestic smoke alarm in each guest bedroom room is a cracker in my view.
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Well worth a read http://www.fire.org.uk/punbb/upload/viewtopic.php?id=786 item 4
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Hi all
Just to let you know I took your advise and contacted Envirograf.
£6148.00 plus VAT to fit the seals to our doors.
Frankly the business does not have that sort of money lying around so ....
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So the perhaps best answer is to identify those doors that are a key priority and upgrade those.
Year 1- doors to staircases and repair any that are a poor fit.
Year 2-doors in dead end bed room corridors and smoke stop doors on corridors
Year 3- doors to other rooms- bars etc that could affect MOE from sleeping areas
Year 4- doors to bedroom corridors where there is two way travel and many bedrooms opening into that section
Year 5- remaining doors.
I am sure no enforcement offier could argue with such an approach.
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Hi Kurnal
Thanks for the suggestion.
I meet with the officer on Tuesday and will put my case based or your suggestion
I really do appreciate your advise
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I like your approach Kurnal and to be honest, I would agree with that as a method I would use.
For me, the priority would be to get rid of the heat detectors in room and have smoke detectors, and before I get ripped to bits, I know all ablout the false alarm issue, but I value the life of an occupant more than the inconvenience of a false alarm.
There are of course, interim measures such as single point detectors where cost is a huge problem.
Current cases have referred to CLG guidance which clearly identifies the level of detection required.
As for the doors, I would advise an audit of all doors and a priority list drawn up (like Kurnals). If a responsible person has a documented actionplan which acknowledges the deficiencies and a course of action to rectify them, then I would accept that as it does demonstrate diligence.
Further inspections would be needed to check progress, but that is a monitoring process, not an enforcement notice issue.
On any audit and inspection, I recommend that doors are brought to current standards perhaps as a rolling program. Only new doors which are installed as a set are, as I understand it, capable of meeting the standard of BS476. (you can all shoot me if that's not right!!)
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Can I ask.
I am happy with Kurnals suggestion of a programme of works.
We have HD's in our bedrooms. Can we change these without re-wiring ??
What about installing battery domestic type smoke detectors in every hotel bedroom?
We would obviously keep the exisitng HD's.
This would cut down on false alarms and have the added bennifit of stopping people smoking (in a non smoking hotel)
Is there any merit in this idea and would it be worth attaching the idea to Kurmals programme.
I appricate that a smoke alarm going off at the far end of the hotel is not going to attract attetion from the front office but as an extra on what we have now !!!!!!!!!!!!!!!!!!!!!!!
I know fires happen but I would be intereted to know just how many false alarms their are every week (reported and not reported...would you guess at 99% or more...
This is one of the problems the fire authorities have. The general public, in my experience, generally don't believe in fire alarms (I mean when the go off)
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Yes the existing heat detectors will adequately protect everybody except persons in the room of origin and will alrt staff if there is a real fire in a bedroom, the self contained smoke alarm will provide protection to the occupants should there be a fire in their own room. Go for mains powered with interlinked in suites.
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We have HD's in our bedrooms. Can we change these without re-wiring ??
yes
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.....What about the poor guy in the room of origin? The record shows he doesnt die anyway. In a study carried out in fires over a 5 year period prior to introducing detectors in bedrooms, not a single sould died from fire in any star rated hotel in the UK. Thos who died in non-star rated accommodation were mostly in hostel-like properties, and those who died in the room of origin were committing suicide or were out of it on drugs or alcohol in the main.
So those who do require s/d in bedrooms are trying to save the lives of those who never die anyway---to the detriment of the safety of others.....
As most of you know I would never be controversial, but on this occasion I must agree with Toddddy.
The person in the room of origin is not particularly at risk. Yes people do of course die in the room of origin but as Toddy correctly points out, not in star rated hotels.
Can anyone tell me of a fire in an hotel where a person died in the room of origin since the previous study was carried out?
In a new installation of course I would always now recommend smoke detection because modern systems can engineer out the false alarm problem.
But in an existing hotel with heat detection would the limited funds not best be spent on upgrading doors rather than spending money solving a problem that statistic prove doesn't exist?
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Yes Phil.
But we must recognise that persons in rooms are relevant persons and even though statistics show people do not die in hotel rooms and you could use this to inform a probabalistic risk assessment, it is much harder to argue from the viewpoint of a qualitative risk assessment.
After all statistics also show that the people who live in category A council tax rated properties dont die in house fires but we impose the same buiilding reguilations requirements for smoke alarms on them as we do the HMOs where 40% of fire deaths occur.
So considering the possibility that a fire does break out in the hotel bedroom, however remote that chance may be as a result of our other risk control measures, will a heat detector give sufficient warning to alart them? No of course we know it wont. Will a smoke detector be any better? Maybe or maybe not- I dont know of any studies that have been carried out on tenability within the room of origin based on a wide range of fire scenarios that would be necessary to come to absolute conclusions, though much was done on this in respect of residential sprinklers.
But if we leave the heat detector in place are we adapting to technical progress? What argument can we use to convince the fire authority and the judge that risk is ALARP if we dont update the detectors?
I too agree with Colin Todds point of view as expressed elsewhere in this forum, but recognise that the problem of false alarms need not now be an issue with multi sensor technology- but for many hotels their existing system would not support this.
I have tried and tested this argument in a number of situations without much success - many brigades have adopted it as a policy to upgrade all detectors to smokes, whereas in other areas they still appear to be tolerating the lowest of standards- with some manual systems still in place. Thats where brigades should focus their enforcement resources not hounding the small B&Bs and making them upgrade to make their homes fit the pictures in the guides.
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I quite agree with all you say Kurnal and yes of course the person in the room is a relevant person. Yes there is a need to adapt to technological progress but I'm not convinced that spending thousands of pounds to replace heat detectors or to place domestic smoke alarms alongside heat detectors is the best way forward.
Hotel with manual fire alarm, no question, upgrade is needed and smoke detection should be used.
Hotel with L3 OR L2 but heat detection within rooms, personally I would live with. As a consultant I would of course recommend that the system be upgraded as part of an ongoing improvement programme.
What if there is heat detection and poor fire doors and limited funds. Would the upgrade of the doors not be better use of available funds.
It is a tricky one for the hotelier because ultimately what he must provide depends on the competence of the consultant, inspector and/or the policy of the FRS, and as we know that varies greatly.
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Perhaps as Phil states a balanced approach would be to agree with the RP that when each room undergoes re-decoration part of the works should involve changing the heat to a smoke detector.
Thats said of course I still take issue to a large degree with the " sacrificial guest" argument. As we know smoke kills, not flame, and our unwitting guest may never wake up by the time the heat detector has activated.
Conversely take a 200 bed hotel - how on earth do they afford to upgrade heat to smoke detection in one go?
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Another way of looking at this, on Legal and Moral grounds.
Assuming you have carried out a fire risk assessment on this 40 bedroom hotel, you look at the doors and there are not any smoke seals anywhere.
You talk about this to the owner who explains hes not got enough money to do the work, because he's had to spend all his money of refiltting the kitchen etc.
After some sole searching you deside not to reccomend smoke seals.
Six months later a fire happens on the middle floor in room 25 at 1.15am, Mr Bigs staying and has gone out for the evening and left his laptop on charge, it bursts into flames because of a battery fault and because it was left on the bed it was soon a very big fire, and because you did not spot that the detector was a 90 degree heat detector the fire is massive before the fire alarm activates.
Before long the room is engulfed in flames and at around the time the 90 degree detector goes off the door fails and smoke is now puthering out in to the hall way, this is rapidly spreading through the hallway. People are evacuating, some are hesitating "it must be a faulse alarm they think" Mrs Smith on the top floor is sound a sleep after her sweet sherry in the bar earlyer and had removed her earing aid along with her false teeth, so does not hea the sounder thats out on the landing. Mr & Mrs Johnson on their honeymoon are dead to the world after spending all evening pub and clubing, those vodka redbulls were going down a treat.
After 9 mins the fire & rescue services attend and find a large group outside, flames are now bursting out the first floor windows and smoke has completely filled the upper floor.
Unfortunately Mrs Smith & Mr & Mrs Johnson never woke up, the drink ensured they were sound asleep and then they peacefully died of smoke inhiliation.
Six months later its your big day, you arrive at court and sat their waiting are Mr & Mrs Johnsons parents along side their three year old sobbing child who was staying at Gran's while mummy & daddy had a honeymoon, Gran points you out as the man who could have made a difference to the out come, Mrs Smiths son is there and hes mad as a box of frogs he is being help back by his wife, he just wants to beat you to a pulp.
In court you sit though the porceedings and all the expert witnessess saying how they all had smoke in their lungs and the fact that the fire never actually got to the top floor. Jack Smith the smoke seal manufacturer brings in videos and documents all about smoke seals the jury see just how good his seals are and that they may have helped save Mrs Smith & the Johnsons. Jack then drops his bomb shell, "the hotel owner even asked for a quote, but said that they were to expensive".
Its now your turn and the best prosicutor in the uk on fire safety ask's you this question. " As the expert advising the hotel owner, why did you not insist on smoke seals in your assessment".
You look around the court and see the shattered look from the Johnsons child and answer " because the hotel owner said he could not afford them"
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Thank you Thomas, I know where you are coming from but it isnt going to be like that.
My argument is not agaisnt the benchmark standards, I am very familiar with them and and their presecessors, have seen fire safety develop from the disasters ands earliest days of the fire Precautions Act and Fectories Act etc evolve into their current state. At every stage I have tried to understand the back ground to the changes made in apporach over the years and wholeheartedly support improvements and criticise errors and fudged issues, as these all too soon become imposed on Responsible Persons by enforcers and building inspectors some of whom should know better.
The benchmark standard is the goal. If all premises met the benchmark standard and was given a set of rules to operate with we wouldn't need tisk assessments- we would be back to the old days of prescription. But people and buildings are diverse with different characteristics and needs and that is why risk assessment is recognised as the most efficient and cost effective way of meeting those needs in an appropriate but proportionate manner. Our goal is to reduce the level of fire risk as low as is reasonably practical- ALARP- and what is reasonably practicable for one building will be insufficient for another building and over the top for another.
So it is unlkrly that I will be in the dock answering your question. Instead I may be explaining how I took account of the level of risk, applied an appropriate action plan to reduce that level of risk taking all factors into account.
I will explain how that plan was produced- by recording and evaluating the Strengths and Weaknesses of the building and its management, identifying the underlying hazard and recommending ways to control them, taking any Opportunities to balance or offset Weaknesses against the Strengths if appropriate, and fully evaluating all Threats from fire.
SWOT analysis and Gap analysis are an essential element of a risk assessment if you want to move beyond the concept of a tick box checklist that any jobsworth can carry out. But whilst the methodology is implicit in PAS79 etc, most do not do it this way and so have to make the building fit the pictures in the guide.
Now please tell me how I can recognise a 90 degree head. Cos in all honesty I cant at the moment and am keen to learn.
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ALARP is the standard and is time trouble and inconvienience versus cost. Proportionality is also a big player as recognised by the Government and its Enforcement Concordat. We all know that the highest standard is the best standard but not every business can afford pressurised staircases and other engineered solutions at the top end of the market. Detection and warning systems are also expensive as are new fire doors. Retrofitted strips and seals are again aan expense and I am not that sure that they will provide the protection required in BS 476 part 22.
However, they all may play a part and all those involved in fire safety as enforcing officers or assessors should know the benchmarks and work towards them as far as possible. As Val indicated in a separate thread, not all buildings can be changed to look like the guides and there nice diagrams so there has to be some degree of common sense approach for all concerned. Again as in a previous thread action plans are a way forward on this but not if they go against a structured FRA which is proportionate to the risk of the premises.
And here I think lies a problem between FRS and there staff and competent RA's. Some FRS staff take no account of ALARP or proportionality and have the belief that all buildings can be adapted to look like the diagrams and that is the end of it.
Many endings to the same story then.
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You have to take ALARP along side all the the other HSE recomendations such as COMAH (control of major accident hazards) and AMN (All measures necessary), ususally in Uk we use SFAIRP. If anyone has got a several hours to read all these rec's most are on the HSE web site. Below is a couple of snippets which highlights some of the points made. Unfortunately these reccomendations can be mislead and I wil demonstrate what I mean in ext paragraph.
These are examples to show a point, I am not saying this is what this particular hotel is doing.
I can apriciate the cost of £6148 is a lot of money so may be is it reasonable practicalble esspecially if the hotel has just a few rooms and turns over is around £40k a year.
How ever Im not sure how many doors this hotel needs altering but I would shop round for prices including looking at buying the seals yourself and paying a chippy to price up installing them. Doing a quick search I found smoke/Fire seals for around £11 each door a good chippy can do a door an hour especially if you get him a helper to take down and re-hang the doors, so you could be looking around £40 per door. Then if you consider this is a 40 bedroom hotel charging £75 per night per room total turn over now is £1,092,000 per year. I think everyone would consider spending £6148 out of a turnover of £1m a year is not a massive drain and would be reasonable to expect it to be done, esspecially if you go along with Kurnals process of phasing it in over a few years.
This now is my opinion and I apriciate a lot on here seem to feel smoke seals are to expensive for the risk and as risk assessing is not perscriptive we will all assess slightly differently, How ever I feel compartmentation and smoke sealing is one of my highest priorites for people protecton especialy in sleeping accomadation. I still feel in a big hotel not looking at smoke seperation may leave an assessor on a sticky footing in a fire death situation.
Legal background to ALARP
The principal health and safety legislation in the uk is the Health and Safety at Work etc. Act 1974 (HSW Act). It requires risks to employees, and others, to be reduced ‘so far as is reasonably practicable’ (SFAIRP). The meaning of SFAIRP has been the subject of legal judgment in the UK courts (Edwards v National Coal Board). Risk assessments are also required by The Management of Health and Safety at Work Regulations, Reg 3.
Regulation 4 of the COMAH Regulations requires Operators to "take all measures necessary (AMN) to prevent major accidents". This is interpreted as the equivalent of reducing risks "as low as reasonably practicable" (ALARP). In terms of what they require of duty-holders, HSE considers that duties to ensure health and safety so far as is reasonably practicable ("SFAIRP") and duties to reduce risks as low as is reasonably practicable ("ALARP") call for the same set of tests to be applied.
The demonstration that AMN have been taken to reduce risks ALARP for top tier COMAH sites should form part of the Safety Report as required by regulations 7 and 8 of the COMAH Regulations. The required level of detail is specified in Schedule 4 to the Regulations.
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Hi Thomas
Yes I agree with most of what you say, The bottom line is that only the Judge can decide whether the duty of care has been met.
Not sure why you refer to COMAH though? "AMN" is a specific duty under COMAH Regs not relevent to the Fire Safety Order which instead point to the duty to implement "general fire precautions"
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HSE thoughts on ALARP etc here: http://www.hse.gov.uk/risk/theory/alarpglance.htm
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Gents,
I enjoy the wonderful exchange of views on this site and particularly in this area and the use of scenarios to illustrate the point, and, although I am admittedly long in the tooth and a bit of a dinosaur try this augment for size:
I will not comply with your recommendation mister fire safety officer from the local brigade to replace my heat detectors with smoke detectors in bedrooms as I fully comply with the latest BS. I quote:
BS 5839-1:2002+A2:2008
Hotels and hostels L1 or L2 In bedroom areas, the design requirements are usually based on the recommendations for a Category L3 system. Detectors are, however, typically installed inmost other rooms and areas, as a fire in almost any area of the building could pose a threat to sleeping occupants; the system Category is, therefore, at least L2. In practice, few, if any, areas are left unprotected and the system Category is effectively L1, except that a variation from the recommendations applicable to a Category L1 system may apply to the siting of heat, smoke or carbon monoxide detectors in bedrooms; this often follows the recommendations of 22.3e) for detectors in a Category L3 system.
And
Similarly, it is acceptable, in a Category L2 or L3 system within a building in which people sleep, to install heat detectors in bedrooms. The objective of these detectors is not to provide the earliest possible warning to occupants of a bedroom in which fire starts, but to warn other occupants before the integrity of the door of the bedroom is threatened by fire. Earlier warning would be given by smoke
This would appear to be the current standard and I note that the HMG guide to sleeping accommodation refers to this BS
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Hi Thomas
I've got a job for you and I will gurantee twice your current salary Plus a new Merc 320E 5 weeks holiday in Rio Ist class and pension IF and only IF you can Turnover £1.092.000 per year for rooms alone at our 40 bedroom hotel, In fact I'll give your wife a Merc as well.
Trust me we would NOT be having a conversation about spending £6000 on smoke seals.
I wish !!!!!!!!!!!!!!!!!!!!!!!
and in any case its not turnover that matters its the bottom line after all the costs (that dirty word profit)
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Davidrh
Thomas is quoting max theoretical turnover.
Say you make £5 per room per night, that is £73k per year.
Say you average 60% capacity each day
That gives you £43,800 profit
Does spending £6148 seem reasonable?
You could do it over two years as the Phil and MR suggest
davo
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Dusty, a well made point.
BS5839 also states :
In England, Scotland and Wales, legislation requires that, where necessary
to safeguard relevant persons in case of fire, premises are equipped with
appropriate fire detection and alarms. Equivalent legislation applies in Northern
Ireland.
So since the person in the room of origin is a relevant person, how are you safeguarding them?
BS also states that the type of system should be subject to a risk assessment. That risk assessment should be looking at how all relevant persons are protected, or how they can be protected.
It is a tough call though. As you say, our very own CLG guides refer to this, and I would expect that if the rest of the fire precautions in the hotel are adequate, then the FRS would lose an appeal on these grounds.
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Hi everone
I need further help here.
The Fire officers who gave me till August to put in smoke seals has now said that my existing intrumisent strips (in my lobby and hallway doors..some double) are also no good and they need smoke seals with brushes "
Is that right ???. Where does this all end ??
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ALARP is the standard and is time trouble and inconvienience versus cost. Proportionality is also a big player as recognised by the Government and its Enforcement Concordat. .
The cost & proportionality part of ALARP worries me.
Does this mean:
If I audit a Hilton or Holiday Inn and find a problem, I should not worry too much about how much it's going to cost to fix, as they are big £multi concerns that can afford the changes.
Alternatively, when dealing with the owner of the scruffy old single staircase sole trader £30-a-night Hotel (yes we do have some in London) down the road, where I find an identical problem, I have to go easy because what I might require is too financially onerous.
Surely using a risk based approach (& using Sir Toddy's argument) the punter in the flea pit is far more likely to die by fire than the 4* luxury Hotel, so surely it is that scruffy Hotel that I should put more pressure on to raise FS standards regardless of costs and not vice versa.
I personally take no prisioners when it comes to (the scruffier) single staircase Hotels, regardless of who runs them and how deep their pockets are. Am I wrong??
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Hi everone
I need further help here.
The Fire officers who gave me till August to put in smoke seals has now said that my existing intrumisent strips (in my lobby and hallway doors..some double) are also no good and they need smoke seals with brushes "
Is that right ???. Where does this all end ??
You have to ask and you have a right to know exactly why "they are no good". "They are no good" is not a good enough explanation if that is what you were advised.
What type of building is it?
Have you carried out a FRA?
What does it say about the doors?
Did you put the smoke seals on the doors (this is August)?
What are the circumstances that made him/her tell you that the intumescant strips are "no good"?
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In response to Messy
Its not particularly about money at all.
Its about how likely a fire is to occur and whether if it does anybody will be hurt. Management is a critical factor probably to a greater extent than passive measures. The scruffy hotel immediatley tells you management is crap- if they arent prepared to improve the management you will compensate by ensuring the passive measures are spot on and check regularly that they are maintaining them. Cos that all you can do in the circumstances.
It doesnt matter though how much we spend on physical fire precautions- if people do the wrong thing they will get hurt. Human factors are by far the biggest cause of accidents in every aspect of H&S.
So proportionality is down to the size, management and character of the premises.
At the hilton there are hundreds of people at risk. Due to numbers there is likely to be a wider more diverse population with more special needs. The buildings are large and high. if someone wedges a door open more people are at risk as a consequence. They are going to get seriously hurt if they jump out of a high window. There are more likely to be more people under the influence and the all night bar encourages this. There may even be none or maybe just one night porter on duty looking after hundreds of people. Theres no way in an emergency anyone can quickly check all guests respond and evacuate. Many will stay put- studies show this. They are likely to stay put until tipped out by the fire service. They will be at risk for longer- and if they do evacuate have longer travel distances to a final exit.
At rose cottage B&B Mr and Mrs diligent have great pride in their home. they have spent a life time accumulating their prized belongings and creating a lovely home. They choose to supplement their income by letting a couple of bedrooms. They cannot take non ambulant people because of the stairs, and are very careful about who they offer a room to. After all ther antique collection is worth thousands. They show each guest around the house and personally tell them the house rules- no candles, no smoking. Mr diligent wont go to bed till the guests have retired. Mr and Mrs diligent sleep in the room next to the guests. If the smoke alarms sound they will make sure the guests respond. This means that the evacuation is over in a couple of minutes, before the folk at the Hilton have even decidsed whether to let the alarm ring a little longer to see if it stops. In view of these measures I suggest that with a good coverage of detectors, good management and supervision, small building, short travel distances even though the nice panel doors are not fire doors Mr and Mrs diligent really dont need to change them.
Thats my view on proportionality.
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David
If you want to call me for a chat feel free to do so. Phone number on the website.
Not looking to pick up a job out of it, we have enough on out plate, its just that there are more questions than can be asked on this forum.